Privacy Policy

We collect personal information only where it is reasonably necessary for our business activities. The types of personal information we may collect include:

• Identity and contact information: name, email address, phone number, postal address, and job title
• Professional and organisational information: employer, role, professional qualifications, and institutional affiliation
• Investor information: financial information, account details, tax file numbers (TFNs), identity verification documents, and information required under anti-money laundering and counter-terrorism financing laws
• Communication records: records of communications between you and Black Kite Partners
• Website usage data: IP address, browser type, pages visited, time spent on pages, and referring URLs (collected via cookies and analytics tools)

We collect personal information directly from you (e.g., via enquiry forms, email, or in-person meetings), from publicly available sources, and from third parties such as our service providers, referrers, and intermediaries. We collect sensitive information, including financial information, only where required for our business purposes and with your consent or as otherwise permitted by the Privacy Act.

Where it is lawful and practicable, we will give you the option of interacting with us anonymously or by using a pseudonym. However, in most cases this will prevent us from providing you with the services you have requested.

We collect, hold, use, and disclose personal information for the following primary purposes:

• Managing our relationships with investors and prospective investors, including conducting due diligence and investor onboarding
• Communicating with investors, prospective investors, portfolio companies, and other stakeholders regarding our activities
• Responding to enquiries and requests submitted via this website or otherwise
• Complying with our legal and regulatory obligations, including obligations under the Corporations Act 2001 (Cth), Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), and applicable tax laws
• Managing our business operations, including recruitment, due diligence processes, and risk management
• Improving our website and services through analytics and feedback
• Sending material communications relevant to your relationship with us, including fund updates and investor reports (where you have consented or where we are otherwise permitted to do so)

We will not use or disclose personal information for a secondary purpose unless you have consented, the secondary purpose is directly related to the primary purpose, or we are otherwise permitted to do so under the Privacy Act.

We may disclose personal information to third parties in the following circumstances:

• Service providers: to our lawyers, accountants, auditors, tax advisers, fund administrators, custodians, technology providers, and other professional advisers who assist us in conducting our business, on a confidential basis
• Regulatory and government bodies: where required by law, including to the Australian Securities and Investments Commission (ASIC), the Australian Taxation Office (ATO), AUSTRAC, or any other regulator with jurisdiction over our activities
• Co-investors and transaction counterparties: in connection with specific investment transactions, to the extent necessary and with appropriate confidentiality protections
• Portfolio companies: as required in connection with our investment management activities
• Successors: to any successor entity in connection with a merger, acquisition, or sale of all or substantially all of our business or assets

We do not sell, rent, or trade personal information to third parties for marketing purposes.

In certain circumstances, we may disclose personal information to recipients located outside Australia, including to service providers, co-investors, or advisers located in countries such as the United Kingdom, the United States, Singapore, or other jurisdictions relevant to a particular transaction or investment.

Where we disclose personal information overseas, we take reasonable steps to ensure that the overseas recipient handles that information in a manner consistent with the APPs, whether through contractual arrangements, binding corporate rules, or by confirming that the recipient is subject to a law or binding scheme that provides substantially similar protections to the APPs.

By providing us with your personal information, you acknowledge that we may transfer it overseas in the circumstances described above, and you consent to that transfer where required.

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification, or disclosure. Our security measures include physical, technical, and administrative safeguards appropriate to the nature and sensitivity of the information held.

Where personal information is no longer required for the purposes for which it was collected (and we are not required to retain it by law), we will take reasonable steps to destroy or de-identify it.

While we take all reasonable precautions, no data transmission over the internet or storage system can be guaranteed to be fully secure. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately.

Subject to certain exceptions set out in the Privacy Act, you have the right to request access to personal information that we hold about you, and to request correction of that information if it is inaccurate, out of date, incomplete, irrelevant, or misleading.

To make an access or correction request, please contact us using the details below. We will respond to your request within a reasonable timeframe. We may need to verify your identity before fulfilling your request. In limited circumstances, we may refuse an access or correction request, in which case we will notify you of our reasons (to the extent we are permitted to do so) and the mechanisms available to you to make a complaint.

Our website uses cookies and similar tracking technologies to improve your experience, understand how visitors use our site, and for analytics purposes. A cookie is a small text file placed on your device by your browser.

You may disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the website. We do not currently use cookies for targeted advertising purposes.

If you believe that we have interfered with your privacy or breached the APPs, you may make a complaint by contacting our Privacy Officer using the details below. We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days. Where this is not possible, we will keep you informed of progress.

If you are not satisfied with our response to your complaint, you may refer the matter to the Office of the Australian Information Commissioner (OAIC):

• Website: oaic.gov.au
• Phone: 1300 363 992
• Post: GPO Box 5218, Sydney NSW 2001

For any enquiries, access requests, correction requests, or complaints relating to this Privacy Policy or our handling of your personal information, please contact: